What a retailer or a wholesaler actually asks you for
Four supplier manuals were read directly for this page, from Zalando, a British department store group, a French department store and a German online retailer. None of them requires a Digital Product Passport. The largest of the four says in its own contractual document that the passport is not obligatory yet. The claim that retailers are already mandating passports traces back to an article about that document rather than to the document itself.
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The short answer
No retailer or wholesale channel in this research requires passport data as a condition of supply.
What they do require splits three ways. Commercial and merchandising data, which is most of it. Identity and safety data, which is the part with law behind it. And, from the one channel that asks for evidence at all, a set of documents attached to an article, in English, as PDFs.
That last point is the useful one, and it is not about what a retailer asks for. It is about the shape of what they ask for, which is a document vault. A passport is structured data behind a resolvable identifier. Nobody is bridging those two objects and nobody is being forced to.
What the manuals actually say
The largest of the four is Zalando's Quality Assurance Manual, which binds partners whether or not they sign it. Its section on the passport, in the current version read for this page and unchanged across the two versions before it, says that even though the passport is not obligatory yet it is expected to come into force, and that early preparation for its requirements and data will help ensure compliance once it does.
Read that sentence carefully, because both halves matter. It is not a mandate. It is Europe's largest fashion platform telling its partners in a contractual document to prepare, accurately, in the present tense. That is a real and useful thing for a brand to know, and it is a weaker claim than the one in circulation.
A search of that same document set for the name of the ecodesign framework returns nothing at all. Zalando's separate Platform Rules mention the passport, the framework and ecodesign nowhere, and describe product sustainability standards as voluntary.
The other three go further in the same direction. The British department store group's supplier manual, revised in the middle of this year, contains no match for sustainability, for the passport, for the framework, for carbon or for recycled content. The French department store makes country of manufacture and sustainability certification optional. The German retailer asks for a product identifier, imagery and trade statistics data.
Where the mandate claim came from
It is worth tracing, because it is a clean example of how a claim in this category acquires authority it never had.
A labelling vendor published an article in early 2025 describing the platform manual above. The article is accurate about what the document contains and misleading about what the document does, in that it presents preparation guidance as a requirement. Subsequent material cited the article rather than the manual. At least one research programme, including one of this estate's own, recorded it second-hand as the first hard evidence of a retailer mandate with a date attached, and let conclusions rest on it.
Reading the manual settles it in about ten minutes.
The general lesson is worth more than the specific correction. A supplier requirement is a document you can obtain. If somebody tells you a retailer requires something, ask which manual, which version and which section. The answer either exists or the claim does not.
Wholesale asks for less, not more
This runs against the intuition. Business buyers scrutinise, so wholesale ought to be where evidence gets checked.
Faire states in writing that the general product safety regime does not apply to business-to-business online platforms like itself, and that no changes are required for product listings. It states separately that product listings on the platform are not linked to physical compliance requirements such as labelling or safety testing.
Its mandatory fields are a name, a description, a wholesale price, a recommended retail price, a case quantity, a minimum order quantity and one image. The only provenance-shaped mandatory field found anywhere in wholesale is a six-digit customs classification code.
Two other platforms frequently named as wholesale channels in this category are no longer operating.
So the channel that ought to demand the most product evidence demands the least, and a brand sequencing its work by where the pressure is will find none there.
What the one channel that does ask for evidence asks for
Zalando collects risk assessments, bills of materials, test reports and declarations of conformity. It collects them as PDF attachments, in English, article by article.
That is the shape worth noticing.
A brand that satisfies it ends up holding a folder of documents indexed by article number. A passport is a different object: structured values, each traceable to the document behind it, reachable from a persistent identifier. The folder does not become the passport by being tidied. Somebody has to resolve each value out of each document and record where it came from, and what each class of document does and does not establish is a subject in its own right, on certificates, declarations and test reports.
There is one further requirement worth separating out, because it is often read as a data requirement and is not. Zalando asks for a minimum size run, three consecutive adult clothing sizes and five for shoes. That is an assortment rule about what you must offer, not an attribute about a product.
And on one attribute Zalando asks for more than the law does, requiring composition broken out by layer where the law requires it for the article. That is a commercial requirement exceeding a legal one, which is allowed, and it is the shape of thing that gets misreported as a legal change. What each kind of document actually establishes is set out in certificates, declarations and test reports.
What the pattern says about sequencing
Put the three demands side by side and the ordering is not the one the category implies.
| What is asked for | Who asks | Does it have law behind it? |
|---|---|---|
| Commercial and merchandising data | Every channel, always | No. It is the price of being listed. |
| Identity, party and safety data | Marketplaces, and the platforms enforcing them | Yes, and it is enforced now. |
| Documents in a vault, per article | One channel of the four read | Partly. The documents exist for other reasons. |
| Passport data | Nobody | No product act has been adopted for textiles. |
The work that is actually forced is the second row, and it is largely about your company rather than your products. The work that would produce a passport overlaps it at the identity and party layer and almost nowhere else.
That does not make passport preparation pointless. It makes the justification for it something other than an imminent retailer demand, and a programme funded on a demand that a buyer can disprove in one click is a fragile programme.
What this page does not say
It does not say retailers will never require passport data. The largest manual read here tells partners to prepare, which is a signal even though it is not a requirement.
It does not name all four retailers. The document carrying the load-bearing finding is named, because that finding is accurate and reflects well on the party that wrote it. The three whose manuals are described by an absence are not named, because an absence in a document is a fact about that document's scope and would read as a judgement about the company. Every claim attaches to the version actually read, and one of the four has a newer version this research did not read.
It does not generalise from four manuals to the retail sector. Four supplier manuals and one wholesale platform's published position is what was read. It is enough to disprove a universal claim that retailers are mandating passports, which is what it is used for here, and it is not enough to describe what retail as a whole requires.
What would overturn this
A supplier manual, from any retailer, making passport data a condition of supply with a date attached. That would be the first, and this page would carry it.
The newer version of the manual quoted above, which has not been read. If its passport section has changed, this page changes with it.
What to do about it
Ask for the document. Which manual, which version, which section. A requirement that cannot be produced in a document is a rumour with a logo on it.
Separate the assortment rules from the data rules. Minimum size runs, imagery specifications and lead times are conditions of trading. They are not product information and they should not be sitting in the same backlog.
Build the folder so it can be resolved later. If a channel makes you assemble documents per article, that folder is the raw material for a passport, but only if you keep which document supported which value. A vault indexed by article number and nothing else has to be read twice. The listing rules that do bind a distance offer are on what a listing has to carry.
Sources
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Four retailer and department store supplier manuals, read directly, versions as read on 27 August 2026First-party supplier documentation
Used for what each requires and does not require, including a term search of one document set for the ecodesign framework which returned nothing. The retailers are described by type rather than named, and each claim attaches to the version read. One of the four has a newer version that was not read, and that is recorded rather than smoothed over.
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A wholesale platform's own published position on product safety scope, November and December 2024First-party platform statement
Cited for the two statements described, and for the platform's published mandatory listing fields.
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A labelling vendor article, early 2025Vendor material
Cited only as the traceable origin of the retailer mandate claim, and for the specific way it differs from the document it describes.
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Marketplace and retailer requirement research, compiled 27 August 2026Field research
Used for the document-vault finding, the assortment rule and the layer-level composition requirement.
Sources as at 30 August 2026.
Keep going
The question this one usually raises next.
Also worth reading
Does this reach your products?
Give ActivateDigital one product and it works out which obligations apply from the product's own character, and says which it cannot decide.
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